What MIPS Changes Are Inside the Proposed 2018 Quality Payment Program

In the transition to value-based care, healthcare providers are feeling heightened pressure to comply with burdensome health IT reporting requirements for MACRA’s Quality Payment Program (QPP). Fortunately, for providers across the country who have expressed concerns with the burden, reporting stresses may soon lessen. After engaging more than 100 stakeholder organizations and with feedback from more than 47,000 professionals, CMS has proposed major changes for QPP Year 2 to ease participation.

MACRA’s QPP centers on improved patient outcomes, activities for quality clinical care practices, efficient use of medical resources and the meaningful utilization of EHRs. As in Year 1, clinicians must report through one of two reimbursement tracks: the Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (APMs).

To understand how the QPP updates may affect healthcare providers, it’s important to take a closer look at some of the language and changes noted in the proposal.

MIPS Participation Updates

While additional types of clinicians may be eligible in the future, the same types of clinicians will participate in MIPS during 2018 as in 2017 (Year 1). This group includes doctors of medicine, osteopathy, dental surgery, dental medicine, podiatric medicine, optometry and some disciplines of chiropractic medicine.

For 2018, however, the exemption threshold has expanded. Now, clinicians or groups that have billed less than $90,000 in Medicare Part B or seen fewer than 200 Part B patients are exempt from reporting. Additionally, individuals who are a new Medicare-enrolled eligible clinician, a qualifying APM participant or a partial qualifying APM participant are exempt from MIPS reporting.

MIPS Performance Period Changes

With the proposed QPP, the Advancing Care Information (ACI) and the Improvement Activities (IA) categories will now require 90 days of performance reporting, while the Quality and Cost categories have increased to a full 12-month span. Both the ACI and the IA categories require the same number of activities for 2018 as in Year 1, but both have expanded in proposed activity options. The Quality category requires six reported measures for individuals or small practices, while large group reporting requires all 17 clinical quality measures. The Cost category will still stand at zero weight for MIPS scoring for Year 2. Reporting data for Year 2 must be submitted by March 31, 2019.

Certified Technology Requirement

Clinicians can continue using 2014 certified EHR technology (CEHRT) for Year 2. However, those who transition to 2015 CEHRT are eligible for a 10 percent bonus under the ACI performance category. CMS will also consider a decertification hardship for those clinicians reporting under MIPS whose EHRs were decertified.

Bonus Opportunities

Beyond the 2015 CEHRT bonus, MIPS-eligible clinicians have other bonus opportunities. If you are in a small practice with 15 or fewer clinicians, your final MIPS score gains a bonus of five points. For those treating complex patients, up to three points can be added as bonus to the final MIPS score, based on the average Hierarchical Condition Categories (HCC) risk score.

Additional Flexibility Measures

A new addition to the QPP for Year 2 is the allowance for virtual group participation for MIPS. CMS is also considering a new hardship exception under the ACI performance category for providers in small practices.

Feedback

Though QPP Year 2 offers added leniencies, CMS is still seeking feedback to lessen physician burden and strengthen program transparency while improving health outcomes. Several areas remain open to comments, like the issue of whether the small practice bonus adjustment should be applied to rural areas as well.

Throughout the healthcare industry, professional associations, including the American Hospital Association (AHA), have already expressed support of the proposed rule.

The 400-page proposed rule will be open for public comment until August 21, 2017. To provide feedback, contact CMS at [email protected].

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Leveraging more than 30 years healthcare industry and management experience with work spanning the public, private, academic and governmental sectors for acute facilities and large physician practices, Joncé serves as the vice president of revenue cycle management at Stoltenberg Consulting. With a special focus on revenue cycle optimization and business office transformation, she also provide support for implementation, roadmap strategy, project management and account oversight. She has successfully led multi-disciplinary teams on large complex projects and oversees all of Stoltenberg’s revenue cycle management work.

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Leveraging more than 30 years healthcare industry and management experience with work spanning the public, private, academic and governmental sectors for acute facilities and large physician practices, Joncé serves as the vice president of revenue cycle management at Stoltenberg Consulting. With a special focus on revenue cycle optimization and business office transformation, she also provide support for implementation, roadmap strategy, project management and account oversight. She has successfully led multi-disciplinary teams on large complex projects and oversees all of Stoltenberg’s revenue cycle management work.